#318 - The Year In Review: Toxics, Part 1, 29-Dec-1992

For two decades, the chemical industry and the federal government kept
the American people focused narrowly on cancer risks from chemical
exposures. Meanwhile, largely unnoticed by science or medicine, many
chemicals have been affecting the human immune system, reproductive
system, and nervous system.

Only a handful of chemicals have been proven to cause cancer in humans.
Many more have been shown to cause cancer in laboratory animals, but an
army of scientists now makes a good living by arguing that animal tests
don't tell us much about humans. While this debate rages, thunderous
quantities of industrial poisons continue to spew into the environment.
The environmental movement and the public have allowed the chemical
industry and their friends in government to define the terms of the
discussion. The result has been two decades of focus on cancer and not
much else. Cancer is important, of course, but so are other health
problems caused by chemicals.

During 1992, non-cancer threats from chemicals began to get the
attention they deserve. For example, SCIENCE magazine, official voice
of the American Association for the Advancement of Science, said April
3 (pg. 28),

IN THE 1980S, HUMAN IMMUNE SYSTEMS WERE FIRST FACED WITH THE BLATANT
DESTRUCTIVE POWER OF AIDS. NOW IN THE 1990S, HUMANS--AND IMMUNOLOGISTS-
-ARE ENCOUNTERING DRAMATIC INCREASES IN YET ANOTHER DISTURBING, THOUGH
FAR MORE SUBTLE PROBLEM: ENVIRONMENTAL POLLUTANTS ARE HAVING A
DELETERIOUS EFFECT ON IMMUNE SYSTEMS INDEED, EVERYWHERE THESE DAYS
DOCTORS ARE SEEING INCREASINGLY SEVERE CASES OF IMMUNE-RELATED DISEASES

A 1992 report by the National Research Council (NRC), titled,
ENVIRONMENTAL NEUROTOXICITY, said, "There is convincing evidence that
chemicals in the environment can alter the function of the nervous
system." The report suggested that chemical exposures may be
responsible for some degenerative brain disorders such as Parkinson's
disease, Alzheimer's disease, and Lou Gehrig's disease (amyotrophic
lateral sclerosis).

NRC said there are 70,000 chemicals now in commercial use and less than
10% of these have ever been tested at all for toxic effects on the
nervous system and "only a handful have been evaluated thoroughly."[1]

Risk Assessment

As the focus of concern shifted away from cancer, critics of risk
assessment became more vocal. Risk assessment is a technique that first
came into use during the Carter administration, then was promoted with
a vengeance during the Reagan/Bush years. Risk assessment is now the
main intellectual prop that allows industries to continue dumping
billions of pounds of industrial poisons into public air and water
supplies. When anyone objects, the poisoners trot out a risk assessment
produced by some high-priced consultant, showing that the risk of
giving anyone cancer is less than one-in-a-million. EPA has blessed
this as the official technique for showing that industrial poisons
rarely, if ever, cause significant harm. In the desperate latter days
of the Bush administration, William Reilly, chief of EPA, even went so
far as to suggest that ALL EPA policy should be based on risk
assessment.

To expose the swindle inherent in all risk assessments, one merely
needs to point out that little or nothing is known about the effects of
chemicals on the immune system, the reproductive system, and the
nervous system. When little or nothing is known, it is obviously
impossible to show that any particular chemical exposure is safe. Under
such circumstances, the only dose known to be safe is zero. Since there
will never be enough research to discover the ill effects of all
INDIVIDUAL chemicals now in use, much less COMBINATIONS of all
chemicals now in use, risk assessment is, AND ALWAYS WILL BE, a sham
and a deception. Scientists like Tom Webster at Queens College in New
York and Mary O'Brien at University of Montana in Billings, and lawyer
Paul Merrell of Alder-Hill Associates in Tidewater, Oregon, have
published devastating critiques of risk assessment.

The National Research Council's study of neurotoxins jolted the
political system into a new awareness of risk assessment. Senator
Edward M. Kennedy (D-Mass.), sponsor of a bill called the "Safety of
Pesticides and Food Act," greeted the NRC report saying, "This report
makes clear how little we know about the health consequences of the
thousands of toxic chemicals that permeate our high-tech society. The
most ominous finding is that current risk assessment methods are not
sensitive enough to detect real and avoidable risks lurking in our
environment."

If 1992 is any indication, risk assessors in 1993 will find themselves
on the defensive.

Incineration

Throughout the 1970s and 1980s, evidence accumulated that all landfills
leak and that there is no affordable way to build a safe landfill. (You
might build a long-lived landfill inside a huge 12"-thick titanium box
welded shut, but no one could afford it.)

As an alternative, industry and its acolytes in government decided to
build thousands of hazardous waste incinerators. To show that these
were safe, EPA developed an elaborate "trial burn" system. Incinerator
operators pick representative wastes that are supposedly harder to
destroy than the other wastes that would be routinely burned. These
harder-to-destroy wastes are called POHCs (principal organic hazardous
constituents). During the trial burn, POHCs in nearly pure form are fed
into the incinerator and what comes out the smoke stack is compared to
what was fed into the furnace. A simple calculation then reveals the
"destruction and removal efficiency" (DRE) of the machine. EPA
established regulations REQUIRING 99.99% DRE FOR ALL WASTES FED INTO
HAZARDOUS WASTE INCINERATORS and they told everyone who would listen
that 99.99% DRE of the POHCs proved beyond any doubt that 99.99% DRE
would be achieved for all wastes fed into the furnace.

In late 1992, this was all revealed as a fraud and a ruse. Greenpeace
chemist Pat Costner unearthed two EPA studies, conducted in 1984 and
1985, showing that no incinerators could meet the established
regulations. Any chemical present in the waste stream at a
concentration below 1000 parts per million (ppm) cannot be destroyed
with 99.99% DRE. Since thousands of incinerators had been sold to the
public by industry and by EPA as "safe" specifically to destroy
dangerous wastes present in concentrations lower than 1000 ppm, it
became clear that this was a public health scandal of considerable
proportions.

In response to the public flap, on September 22, 1992, EPA's director
of the office of solid waste, Sylvia Lowrance, wrote a memo to all 10
regional EPA offices, suggesting ways to avoid acting upon the
discrepancy between the requirements of the law and the actual
operating characteristics of hazardous waste incinerators. It seems
clear that, according to EPA's regulations, all hazardous waste
incinerators should be shut down because the regulations say, "the DRE
performance standard applies to each waste feed burned." Since no
incinerators can meet the 99.99% requirement for all wastes burned, no
incinerator meets EPA regulations. Ms. Lowrance's memo seemed to be
aimed at showing EPA staff how to evade the requirements of the law--a
kind of guidance EPA officials are not supposed to give.

On December 22, in a letter to the EPA inspector general John Martin,
EPA employee William Sanjour formally charged Sylvia Lowrance with
violations of law.[2] The inspector general is now required to conduct
an investigation.

Our hat is off to Mr. Sanjour for his fortitude and persistence. Let us
hope the new administration recognizes what an asset he is to the EPA.
Many of the suggestions in his 1992 report, WHY EPA IS LIKE IT IS AND
WHAT CAN BE DONE ABOUT IT, could make any government agency work
better.[3] Lead in Children

The federal Centers for Disease Control in 1992 officially reduced the
amount of lead that is considered "acceptable" in children's blood,
from 25 micrograms per deciliter to 10 micrograms per deciliter.

As the year wound down, a spate of studies began appearing in medical
journals indicating that even 10 micrograms per deciliter is associated
with permanent loss of IQ. The NEW ENGLAND JOURNAL OF MEDICINE reported
October 29 (pgs. 1279 and 1308) that low levels of lead in young
children don't merely "delay neurobehavioral or motor development" but
actually produce "deficits in intelligence." At least three studies of
children exposed to lead before the age of 4 have now shown that the
damage is measurable during school years, ages seven to 10. One study
of well-to-do children in Boston showed that each increase of 10
micrograms of lead per deciliter of blood at age 2 produced a six-point
decrease in IQ at age 10. This held true in the range 0 to 25
micrograms per deciliter, which means that a child with 25 micrograms
of lead in his or her blood at age 2 would lose 15 IQ points compared
to what his or her IQ would otherwise have been. Such a decrease might
not debilitate a person who started with a 125 IQ, but it would
devastate a person at the lower end of the normal range of
intelligence. A person pushed from a 90 to a 75 IQ would face a
lifetime of serious learning disabilities and expensive remedial help.

Late in 1992, the Bush administration responded by issuing rules
requiring all children on Medicaid to be screened for lead. However,
the new rules allowed states to continue using outmoded screening
techniques that cannot detect lead below 25 micrograms per deciliter,
no doubt intended as a kinder, gentler way of continuing to ignore this
menacing problem.[4]

[2] We covered this story in greater detail in RHWN #280 and #312.
William Sanjour's 8-page letter to the inspector general is available
from us for $4.00.

[3] William Sanjour, WHY EPA IS LIKE IT IS AND WHAT CAN BE DONE ABOUT
IT (Annapolis, Md.: Environmental Research Foundation, 1992); $15 from
E.R.F., P.O. Box 5036, Annapolis, MD 21403-7036; phone (410) 263-1584.